Judicial Council Decisions Search
Decision No. 440
April 13 1978
In Re: A Request from the College of Bishops of the Southeastern Jurisdiction for a Declaratory Decision on the Legality of an Annual Conference Requiring More than One Year Under Episcopal Appointment and Formal Supervision by a District Superintendent for Eligibility for Full Conference Membership and Elders Orders, in Light of the Provisions of Discipline Paragraphs 421 and 702.3.
Digest of Case
An Annual Conference has the authority to require of candidates for full ministerial membership more than one year under episcopal appointment and under the supervision of a district superintendent.
Statement of Facts
The 1976 Discipline modified "Requirements For Admission" of persons into membership in full connection in an Annual Conference. Paragraph 421 states: "They shall have (1) served full time under episcopal appointment under supervision personally assumed or delegated by the district superintendent satisfactorily to the Board of Ordained Ministry for at least one full Annual Conference year following the completion of educational requirements." Paragraph 702.3 further states: "The Annual Conference may admit into membership only those who have met all the Disciplinary requirements for membership and only in the manner prescribed in the Discipline." The College of Bishops of the Southeastern Jurisdiction requested a declaratory decision as to the constitutionality, meaning, application or effect of the two paragraphs referred to above in light of ". . . a practice which has developed in some of our Annual Conferences in that we require more than one year under episcopal appointment, supervised personally by a district superintendent in the Annual Conference before one is eligible for full membership and ordination as an Elder." JURISDICTION The Judicial Council has jurisdiction under Paragraph 2515.2(d) of the 1976 Discipline. ANALYSIS The question is: Does an Annual Conference have the right to establishrequirements for reception into full ministerial membership in the Conference in excess of the requirements established in the Discipline? An Annual Conference has wide discretionary powers in the exercise of its own responsibilities in matters relating to Conference membership and ordained ministry within the framework of the Discipline. While the Judicial Council held in Decisions No. 313, 318 and 325 that an Annual Conference could not enlarge nor reduce the requirements for ordained ministry that the General Conference had established, in the case at hand the Discipline specifically allows for going above the minimal requirements. Persons seeking ministerial membership in an Annual Conference must apply through the Board of Ordained Ministry in the manner described in the Discipline. The Board of Ordained Ministry must report its recommendations to the Annual Conference where final authority resides. (Decisions 344, 405) The specific issue is: May an Annual Conference extend the Disciplinary requirementof episcopal appointment and supervision of a district superintendent beyond the one year specified in the Discipline? It is important to note the wording of the Paragraph in question (421): ".. . must have served at least one full Annual Conference year". The deliberate choice of the words "at least" and "one full Annual Conference year" (DCA. Cal. Item #1037, p. 632) implied strengthening and clarification of minimal standards while allowing for possible additional requirements. The words "at least" open the door to increased requirements while observing the rules, regulations and standards of the Division of Ordained Ministry in keeping with the Discipline. (Paragraph 731.2m) The Board of Ordained Ministry is directly responsible to the Annual Conference (Paragraph 731.1a) and must report its recommendations to that body. It does have broad discretionary powers and may recommend additional policies, rules and standards regarding conference membership. It does not have authority to enact such policies, rules and regulations without the approval of the Annual Conference. If an Annual Conference so desires, it may establish standards in excess of, but not less than, nor in conflict with, Paragraph 421 of the Discipline.
An Annual Conference has the authority to require of candidates for full ministerial membership more than one year under episcopal appointment and under the supervision of a district superintendent. Concurring Opinion We agree with the foregoing decision, but would place it upon a broader basis. The analysis emphasizes the inclusion in paragraph 421 of the words "at least" in distinguishing the present question from Decisions 313, 318 and 325. We would have reached the same conclusion in the absence of those words, for we see no constitutional prohibition invalidating action by an Annual Conference adding to the Disciplinary requirements for ordination an additional factor in no way inconsistent, or out of harmony, with any General Conference legislation on the subject. Decision No. 325 is clearly distinguishable. In that case the action of the Annual Conference would have restricted and altered the itinerant ministry and perhaps even separated from it some appointments that the General Conference had specifically provided should be included. In Decision No. 313 and 318, Annual Conferences sought to require of candidates for admission on trial a pledge of abstinence from the use of tobacco or alcohol. Essentially the same requirement had long been part of the Disciplines of both the Methodist Church and the Evangelical United Brethren Church, but after prolonged debate (DCA 580-602) the Uniting General Conference of 1968 adopted the requirement now found in Par. 414.7(2). At the same time the General Conference adopted a resolution of interpretation which was printed in the 1968 Discipline as a footnote to Paragraph 318.7. Therein was stated the intention of the General Conference to elevate the standards of moral commitment. The effect of the attempted reversion to the earlier provision could be considered, therefore, to detract from, and unconstitutionally conflict with, positive General Conference legislation on a distinctively connectional matter. In any event, we are persuaded by the logic of Decision 316 in which the Iowa Annual Conference sought to add to the Disciplinary requirements for admission into full membership. The rule was held invalid because of delegation of authority to the Board of the Ministry with respect to a decision that can be made only by the Conference itself but the reasoning is to the effect that an Annual Conference has the authority and power to adopt a rule adding to the Disciplinary requirements for admission into membership. We believe that is the situation before us. We do not find that the proposed requirement in any way conflicts with any express or implied action of the General Conference and therefore would uphold the authority of an Annual Conference to make its own decision on such a subject. Leonard D. Slutz Hoover Rupert Gene E. Sease